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The Netherlands is the sixth largest economy in the European Union and a global financial center. Due to its business-friendly climate and favorable tax regime, the Netherlands is an attractive location for corporate headquarters and for structuring international transactions.

In a recent case between the owner of a plot with a number of business premises, and the local residents, the Dutch Data Protection Authority (the DDPA) ruled that the owner is allowed to protect its property with camera surveillance.

After years of discussions, the General Data Protection Regulation (the GDPR), has finally been adopted and is due to come into effect 25 May 2018. The GDPR will replace the current Data Protection Directive and will be directly applicable in all EU member states.

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Heico ReinoudPartner

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Experience

Insights

Activities and Affiliations

Areas of focus

Heico Reinoud is a partner and a co-head of the Tax practice group in Amsterdam. Heico has a broad advisory experience in Dutch corporate income tax and dividend withholding tax planning, European tax law and international tax aspects of cross border transactions.

He advises real estate and private equity firms with respect to fund location and formation, structuring their investments and financing of their acquisitions. He assists pension funds and insurance companies with respect to Dutch dividend withholding tax refund procedures. Heico also advises multinationals with regard to mergers and acquisitions and internal reorganizations. He further assists his clients with obtaining advance tax rulings (ATR) and advance pricing agreements (APA) and negotiates on their behalf in tax disputes.

More recently, he has advised on matters concerning OECD's Base Erosion and Profit Shifting (BEPS), EU State Aid and Country by Country Reporting (CbCR).

Experience

Tax advice

Real estate fund: Establishing a Dutch investment and service platform for a Johannesburg and Amsterdam listed real estate fund to invest in shopping malls in Central and Eastern Europe.

Real estate fund: Providing tax advice to a Dutch shared service center of a Vienna and Amsterdam listed real estate fund and assisting them with in obtaining ATRs and APAs.

Communications company: Advising on the sale and transfer of a satellite television service business from the Netherlands to Luxembourg, without triggering immediate taxation on goodwill and surplus value.

Private equity fund: Providing tax advice to a Luxembourg private equity fund that invests through their Dutch investment and service platform in real estate in Spain, Italy and Greece.

Consumer good company: Advising on the tax aspects of the acquisition and integration of a US and Italian based multinational.

French multinational: Advising on the transfer of a trademark from the Netherlands to France, without triggering immediate taxation on the surplus value.

Real estate fund: Serving as the tax advisor of a Johannesburg and Mauritius listed real estate fund that invests through their Dutch investment and service platform in real estate in Poland and the Czech Republic.

Financial institution: Advising on the cross-border transfer of the seat of a financial institution from Curacao to Luxembourg and the subsequent cross-border merger into a Dutch affiliate of a Dutch bank.

Real estate fund: Serving as the tax advisor of a South African listed real estate fund that invests through their Dutch investment and service platform in real estate in Portugal and Slovenia.

Tax insurance companies: Issuing opinions with respect to the survival of Dutch tax losses upon the sale of shares, application of a Dutch real estate transfer tax exception, and the right to deduct related party interest expenses.

Tax litigation

Israel-based multinational: Leading the court procedure to claim a Dutch fiscal unity between sister companies. The case is currently pending before the Dutch Supreme Court.

Dutch company: Leading the court procedure to claim interest deduction with respect to bonds issued by a Dutch company to use the proceeds to invest in rented out logistic real estate.

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